I just wanted to make all prosecutors aware of the fact that beyond his traditional role of an expert defense witness during sentencing to quite predictably testify that an individual is a low risk to the community and/or victim to re-offend, Matt Ferrara has also taken it upon himself to testify DURING GUILT INNOCENCE as to the DEFENDANT'S MENTAL STATE at the time of the offense(s). He bases this type of testimony on Dr. Cunningham's model (which is typically used during sentencing and in capital cases or murders.

I was very surprised when this occured during my trial and I am pretty sure that he has never testified in this capacity before, but perhaps he has, becuase on the stand when asked he couldn't recall.

The bottom line is to BEWARE and to BE PREPARED for this type of testimony. Also, PLEASE it is very important to collect as many transcripts and documents that we can to share and assist each other. If you have anything, please contact me at 512-463-0255.

hsy